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Environmental Assessment for 
Power Purchase Agreement 
Photovoltaic Solar Array Installation 

102 nd Intelligence Wing 

Otis Air National Guard Base 

Massachusetts Military Reservation 



May 2013 



EXECUTIVE SUMMARY 



The 102nd Intelligence Wing Environmental Management Office has prepared this Environmental Assessment to 
comply with the National Environmental Policy Act of 1969, as amended. This document evaluates the potential 
environmental impacts of the proposed Air National Guard 20-year lease of land on the Massachusetts Military 
Reservation (MMR) Landfill to a private entity for construction and operation of a solar photovoltaic system (SPVS). 
The proposed actions would support the Energy Policy Act of 2005 and and Department of Defense energy policy 
goals. 

The SPVS would provide Otis ANGB with a cost-efficient renewable energy source to augment the existing 
ommercial power supply, which relies heavily on fossil fuels. The SPVS would consist of solar panel arrays sufficient 
to generate up to 6 megawatts for consumption solely by Otis ANGB. The arrays will consist of surface-mounted 
solar photovoltaic panels and associated support infrastructure on approximately 37 acres of the landfill cap. In 
non-cap areas, conduit could be run underground to connect the array to the transformers and the transformers 
to the main power grid, which runs past the site. There would be light construction activities associated with the 
proposed project, such as minor trenching, building a surface access road, and the non-invasive assembly of the 
arrays. 

Based upon the nature of the activities that would occur under the proposed and alternative actions, Otis ANGB 
environmental program managers determined that the following resources would not be adversely affected: land 
use, air installation compatibility, air quality, noise, water resources, cultural resources, geology and soils including 
Environmental Restoration Program (ERP) sites, socioeconomics, safety, occupational health, and hazardous 
materials and hazardous and solid waste. The existing conditions were evaluated and documented as the basis for 
determining the environmental consequences. 

There is a minor impact to biological resources. During the filing of the project notification to the Massachusetts 
Environment Policy Act (MEPA), seven breeding pairs of three bird species which were found on the site were 
identified as threatened or endangered by the Commonwealth of Massachusetts; the Upland Sandpiper 
(Endangered), the Vesper Sparrow (Threatened), and the Grasshopper Sparrow (Threatened). In consultation with 
the Massachusetts Division of Fisheries and Wildlife, Natural Heritage and Endangered Species Program (NHESP), 
the 102nd IW and MMR have agreed to a mitigation plan to replace the grassland habitat disturbed by this project 
by declaring another tract of Otis ANGB land surplus which will then become part of an existing wildlife 
management area which abuts the base's southern boundary. 



ACRONYM LIST 



AFCEC Air Force Civil Engineer Center 

ANGB Air National Guard Base 

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act 

CFR Code of Federal Regulations 

EA Environmental Assessment 

EO Executive Order 

EPA Environmental Protection Agency 

IRP Installation Restoration Program 

IW Intelligence Wing 

MEPA Massachusetts Environmental Policy Act 

MMR Massachusetts Military Reservation 

MPP Mashpee Pitted Plain 

MW Megawatt 

NEPA National Environmental Policy Act 

NHESP Natural Heritage and Endangered Species Program 

NREL National Renewable Energy Lab 

NWOU Northwest Operable Unit 

O&M Operations and Maintenance 

PCM Post Closure Monitoring 

PPA Power Purchase Agreement 

PV Photovoltaic 

ROD Record of Decision 

SPVS Solar Photovoltaic System 

USAF United States Air Force 



TABLE OF CONTENTS 

ACRONYM LIST 3 

TABLE OF CONTENTS 4 

1.0 PURPOSE, NEED, AND LOCATION FOR PROPOSED ACTION 1 

1.1 Purpose and Need for Proposed Action 1 

1.2 Location of Proposed Action 2 

2.0 DESCRIPTIONS OF PROPOSED ACTION AND ALTERNATIVE ACTIONS 5 

2.1 Proposed Action 5 

2.2 Alternative Action 1- Other Otis ANGB Locations for Solar 1 6 

2.3 Alternative Action 2 -Other Otis ANGB Locations for Solar 2 6 

2.4 Alternative Action 3 -Other Generation Technologies 6 

2.5 No-Action Alternative 7 

2.6 Federal, State, and Local Permits, Licenses, and Fees Required 7 

3.0 AFFECTED ENVIRONMENT 8 

3.1 The MMR Installation Restoration Program 8 

3.2 Land Use -Description of the Landfill and IRP 8 

3.3 Air Installation 11 

3.4 Air Quality 11 

3.5 Noise 11 

3.6 Base Utilities 12 

3.7 Water Resources 12 

3.8 Biological Resources 13 

3.9 Cultural Resources 14 

3.10 Geology and Soils 14 

3.11 Socioeconomics 14 

4.0 ENVIRONMENTAL CONSEQUENCES 15 

4.1 Land Use 15 



4.2 Air Installation Compatible Use Zone 15 

4.3 Air Quality 15 

4.4 Noise 16 

4.5 Base Utilities 16 

4.6 Water Resources 16 

4.7 Biological Resources 17 

4.8 Cultural Resources 18 

4.9 Geology and Soils 18 

4.10 Socioeconomics 18 

4.11 Safety and Occupational Health 19 

4.12 Hazardous Materials/Waste and Solid Waste 19 

5.0 IRREVERSIBLE AND IRRETRIEVABLE COMMITMENT OF RESOURCES 20 

6.0 CUMULATIVE IMPACTS 20 

7.0 CONSULTATION AND COORDINATION 21 

LIST OF PREPARERS 22 

WORKS CITED 22 

APPENDICES 22 



1.0 PURPOSE, NEED, AND LOCATION FOR PROPOSED ACTION 
1.1 Purpose and Need for Proposed Action 

Executive Order (EO) 13423 (Strengthening Federal Environmental, Energy, and Transportation 
Management) and EO 13514 (Federal Leadership in Environmental, Energy, and Economic Performance) 
established goals and requirements for federal agencies to reduce emissions of greenhouse gasses and 
other air pollutants, and improve energy efficiency by implementing renewable energy projects on 
government properties and by obtaining electricity from renewable energy sources when practicable. In 
response to EO 13514, the Department of Defense has set a goal of reducing greenhouse gas emissions by 
34 percent compared to a 2008 baseline. The Proposed Action will help to meet the goals of EOs 13423 
and 13514. 

The 102 nd IW on Otis ANGB is the host unit with respect to utilities on the MMR. Most other units on the 
MMR (Army National Guard, US Coast Guard, Dept of Agriculture, among others) receive their power 
through the Otis ANGB base grid and are metered and charged by the 102 n IW. Otis ANGB buys all of its 
power from Hess on a regional contract negotiated by the Defense Logistics Agency. It is distributed to 
the base by NStar, the local distribution company serving Cape Cod and southeastern Massachusetts. Otis 
ANGB receives two bills; one from Hess for power usage, the other from NStar for transmission and 
distribution. 

The governing headquarters for Otis ANGB is the National Guard Bureau which provides liaison and 
shared situational awareness capability and serves as a channel of communications among the National 
Guard Joint Force Headquarters - State (NGJFHQ - State), the Joint Staff, US Air Force Combatant 
Commands, the Military Departments, and the Office of the Secretary of Defense. Additionally, it 
facilitates coordination between DoD Components, NG JFHQs-State, and the NG of the several States to 
enhance unity of effort. In this capacity, the National Guard Bureau is key to the apporval chain for this 
project wich ultimately ends with the Office of the Secretary of Defense. 

The vast majority of the electricity in New England is produced by steam turbine generators, which are 
fueled by non- renewable resources such as coal and natural gas. Lease of Otis ANGB land for the 
construction and operation of a SPVS, which would provide the base with up to 25% of its required 
electricity, will substantially decrease the MMR's reliance on non-renewable energy sources. The 
proposed actions would support the Energy Policy Act of 2005, increase overall DoD use of renewable 
energy, and allow Otis ANGB to meet, nearly two decades in advance, the DoD installation energy policy 
long-range goal for renewable energy use. 



1.2 Location of Proposed Action 

The proposed location was identified as a result of a feasibility study funded by the Environmental 
Protection Agency (EPA) and published by the National Renewable Energy Laboratory (NREL) in July 2011. 

MMR has three landfill caps that are suitable for ground-mounted PV systems. For this report, the caps 
are numbered I, 2, and 3, from west to east. These caps have short vegetation without any trees, so there 
are no significant shading issues. The caps are relatively flat on top with slopes ranging from 2.0 to, 3.5, 
degrees and are uniform in all directions. Only the relatively flat areas and southern facing slopes were 
considered for PV systems. The remaining areas of the landfill caps were not considered for a PV system 
because of slope and orientation. 

The landfill is managed by the Air Force Civil Engineering Center (AFCEC) as part of the MMR Installation 
Restoration Program (IRP). Details of the landfill site and its associated management plan are outlined in 
Section 3: Affected Environment. 



fO'SC'O-W 70"IS'*-W 7W«"W 



*1°4J'CrN- 



Proposed Solar Array Site - Capped IRP Landfill 




Proposed Site 



Figure 1: Location of MMR and Proposed Solar Array Installation 




Figure 2: Close up of proposed SPVS locations on landfill caps and type of species in each area. A total of seven nesting pairs were found in 2012. 



2.0 DESCRIPTIONS OF PROPOSED ACTION AND ALTERNATIVE ACTIONS 
2.1 Proposed Action 

Otis ANGB proposes to lease 60 acres of the capped landfill adjacent to Connery Ave., and managed by 
the Air Force Civil Engineering Center's (AFCEC) Installation Restoration Program, to a third party for a 
period of 20 years for construction of a (SPVS). Through a power purchase agreement between Otis ANGB 
and the SPVS developer, the SPVS would provide Otis ANGB with a cost-efficient renewable energy source 
to augment the existing energy provided by Hess via NStar. The array will reduce Otis ANGB's dependence 
on the commercial power supply and contribute toward the MMR's energy security. 

The SPVS would consist of solar panel arrays sufficient to generate up to 6MW DC that would be 
transformed to 4.6 MW AC. The system will likely consist of fixed arrays mounted at a 30 degree angle 
facing to the south. The final layout and selection of specific panels and mounting parameters will be at 
the discretion of the chosen contractor to maximize output on the site. The arrays would be held on 
ballasted, surface-mounted frames so as not to penetrate the surface of the landfill cap. 

The SPVS would tie into the Otis ANGB electrical system at one site on a nearby overhead circuit, East 
Feeder A, which runs along the southern end of the site. The SPVS would be designed to shut down 
immediately if the Otis ANGB power system fails. The interconnection will be installed with appropriate 
electrical protection to prevent damage to either the base grid or the solar array in the event of an 
electrical mishap. 

All power produced from the SPVS would be used by Otis ANGB once a lease is executed, a Power 
Purchase Agreement (PPA) approved, and the SPVS constructed. It is estimated that the SPVS would meet 
25% of Otis ANGB's annual electrical power demands. Electric meters would be placed at the interconnect 
point to quantify the exact output to Otis' feeder. There would be potential for some power to 
intermittently travel backward through the Otis transformer and into the NStar system on days when the 
SPVS produces more power than the base demands. 

Cables connecting the inverters to the grid interconnection would be placed underground in trenches (as 
these will not be on the capped area) that could be as deep as three feet and covered with earth. 
Following emplacement of the conduit, disturbed areas would be graded to maintain current drainage 
patterns. 

A temporary staging area, where solar panels would be assembled, and other construction equipment 
and material would be stored, would be designated in the project area. The entire landfill site is enclosed 
by a chain link fence with a gate, and would not require any secondary security. Regular cleaning of the 
solar panels would be accomplished by either rinsing with water, blowing with compressed air, or a 
combination of both. All solid waste generated during construction, operation, maintenance, and 
decommissioning would be removed by the contractor and disposed of at an appropriate disposal facility 
outside of Otis ANGB. At the end of the 20 year lease, the contractor will remove the entire array and 
associated equipment and restore the site to its original condition. 



2.2 Alternative Action 1 - Other Otis ANGB Locations for Solar 1 

This alternative considered the collective use of several detached parcels of land within the secure area of 
Otis ANGB . However, this alternative is not preferred for several reasons. In order to maximize the 
amount of solar power generated to make the project commercially worthwhile to a contractor, several 
detached parcels of land, each more than 500 yards from each other, would be needed. While a total of 
approximately 4 MW could be installed across these collective parcels, this alternative requires more 
transformers, interconnects, cabling, and security fencing than the proposed alternative, eroding the 
economic benefit and commercial incentive. Further, since these collective sites are all within the secure 
area (Otis ANGB is a secure area within the already-secure MMR), additional administration would be 
needed to ensure proper access. This alternative would result in reduced economic and commercial 
benefit to the contractor while increasing administrative costs and security oversight to Otis ANGB . This 
alternative would continue to leave the capped landfill as an untapped underutilized resource. 

2.3 Alternative Action 2 - Other Otis ANGB Locations for Solar 2 

Other parcels which are on ANGB controlled land but not within the secondary cantonment area were 
also considered. However, just as presented in the Alternative 1 discussion above, similar inefficiencies 
and reduced economic benefits and commercial incentive would result. Additionally, due to their location 
the parcels have specific suitability and utility for future development and prospective missions at Otis 
ANGB . Since some of the parcels involve protected managed grasslands there would be a requirement to 
address environmental impacts through environmental mitigation activities. Finally, development of a 
SPVS on these parcels, based on their location, would negatively impact the overall esthetic appearance 
of the installation. An SPVS on any of these parcels are deemed incompatible with design standards at 
the Massachusetts Air National Guard's premier installation. 

2.4 Alternative Action 3 - Other Generation Technologies 

In 2010 AFCEC conducted a study of the MMR to evaluate suitable sites for wind turbines and other 
alternative energy technologies on the Reservation. This study identified five optimum locations for wind 
turbines and ruled out the feasibility of other renewable energy generation systems such as geothermal 
and hydrokinetic. At the time of Request for Proposal issuance for this SPVS project, all five of these wind 
turbine locations will have a wind turbine installed or construction under way. Other potential sites for 
wind turbines were identified in the study but are not preferred because they are limited in the amount of 
energy they could produce. Other alternative energy generation systems were deemed unsuitable for the 
MMR because the resource do not exist. 



2.5 No-Action Alternative 

The No Action Alternative does not meet the purpose of the project to generate renewable energy 
electricity in an cost effective method in order to reduce the electrical costs associated with the essential 
operations at Otis ANGB and the MMR. Nor does this alternative address the need to meet the goals and 
requirements of EOs 13423 and 13514. It does not contribute to the energy security and independence of 
the base and, finally, if the No-Action Alternative is chosen, Otis ANBG will incur an additional $13 Million 
of energy costs over the next 20 years that could be avoided by commercial development of a SPVS. 

2.6 Federal, State, and Local Permits, Licenses, and Fees Required 

• Interconnection Agreement with NStar 

• Conservation Management Permit issued by NHESP 

• Permit to net meter from Massachusetts Department of Public Utilities (not required if not net- 
metered) 



3.0 AFFECTED ENVIRONMENT 

3.1 The MMR Installation Restoration Program 

The IRP at the MMR is managed by the Air Force Civil Engineer Center (AFCEC). The IRP is being 
conducted in accordance with the Comprehensive Environmental Response, Compensation, and Liability 
Act (CERCLA) of 1980, as amended by the Superfund Amendments and Reauthorization Act of 1986, and 
to the extent practicable, the National Contingency Plan. The MMR is listed on the National Priorities List 
as Otis Air National Guard/Camp Edwards in Falmouth, Massachusetts. The Comprehensive 
Environmental Response, Compensation, and Liability Information System number for the MMR site is 
MA2570024487. 

The DoD (United States Air Force [USAF]) is the lead agency for CERCLA remedial actions at the MMR. 
EPA, USAF, and National Guard Bureau (NGB) are parties to the Federal Facility Agreement for the MMR. 
The Massachusetts Department of Environmental Protection (MassDEP) is not a signatory of the FFA, but 
is an active participant in the clean-up process and provides guidance and direction to the process 
through several chartered boards and committees. 

3.2 Land Use - Description of the Landfill and IRP 

The landfill is located in the southern portion of the MMR and is bounded by Turpentine Road to the east, 
Frank Perkins Road to the west, Herbert Road to the north, and Connery Avenue to the south. The landfill 
occupies approximately 100 acres of open to heavily wooded terrain and began operating in 1941 as the 




Figure 3: The capped landfill - proposed location for 6 megawatt SPVS installation 



primary solid waste disposal facility at MMR. From the late 1940s until 1984, unregulated disposal 
activities were conducted at the site; from 1984 to 1993, regulated disposal activities were conducted by 
the NGB at the landfill as a component of the MMR Hazardous Waste Management Plan. Disposal at the 
landfill occurred in six areas consisting of five distinct cells and a natural kettle hole. The cells are 
designated by the years representing the approximate end date of waste disposal activities. The six 
disposal areas include the 1947, 1951, and 1957 cells, referred to as the Northwest Operable Unit 
(NWOU), which occupy approximately 40 acres of the total landfill area; and the 1970 and Post-1970 cells 
and the Kettle Hole, which occupy approximately 50 acres. The remaining 10 acres comprise the space 
between and surrounding the cells. The thickness of waste burial has not been accurately determined, 
but is estimated to be about 20 feet thick for the 1970 and Post-1970 cells; while the thickness of waste in 
the Kettle Hole is unknown. Approximately 100 additional acres were used in and around the site for 
construction soil material borrow pits, access roads, staging areas, etc. 

Accurate documentation of the wastes disposed of at the landfill does not exist. The wastes are believed 
to include general refuse, fuel tank sludge, herbicides, solvents, transformer oils, fire extinguisher fluids, 
blank small arms ammunition, paints, paint thinners, batteries, dichlorodiphenyltrichloroethane (DDT) 
powder, hospital wastes, municipal sewage sludge, coal ash, and possibly live ordnance. 

Environmental investigations and risk assessments for the landfill indicated that through residential 
exposure to source area groundwater there was risk that exceeded the U.S. EPA and MassDEP criteria for 
cancer and non-cancer target risk levels. An interim remedy was selected that was designed to protect 
human health and the environment and comply with applicable or relevant and appropriate 
requirements. The interim remedial action for the landfill consisted of the following actions: 



Leaving NWOU wastes in place beneath the soil and vegetative cover and installing down 
gradient monitoring wells to assess any impacts to groundwater from the older cells and to 
determine if the interim remedial action is an appropriate long-term remedial action. 
Construction of a landfill cover system (consisting of an impermeable cap) on the 1970 and Post- 
1970 cells and the Kettle Hole. 

Preparation of a post-closure monitoring (PCM) plan for the 1970 cell, the Post-1970 cell, and the 
Kettle Hole. 



Closure activities at the landfill, including capping the three most recently used cells (since they were the 
apparent sources of groundwater contamination) and instituting PCM, were completed in December 
1995. In addition to the caps, the landfill cover system includes an associated drainage system, and 70 
gas vents designed to release gas from the interior of the landfill. Gas probes are located around the 
perimeter of the caps to monitor subsurface vapor. A perimeter fence already existed around the entire 
landfill (capped cells and NWOU) at the time of capping. The primary purpose of the landfill cover and 
associated drainage structures is to minimize the amount of precipitation that infiltrates the landfill and 
produces leachate (water containing contaminants, nutrients, and microorganisms) that could reach the 
aquifer. 



**OAS VEHT 



Cft 



GROUND tUKfiit 




12-DfUUHAOESWID 

GEOUEUBflAHE 

(40 Ml VLWEt 

GEO SYNTHETIC 
CLAT UHCH 
(GUNDStALI 



5UE1GRADE MATERIAL - 






SSSSSSSSSSSSS^SSSSSSSSSSSSSSSSSSSSSSS^^^^S 



MATERIAL 


HYDRAULIC 

CONDUCTIVITY 

(cm/HC) 


(WMNAGE SAND 


>1 x 10 


GEQSYNTMfTll- 
CLAY UNEH 


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GASCOU-ECTVON 

SAND 


»s„,o 3 



WOT TO SCALE 



ABB 



LANDFILL COVER SYSTEM 
PROFILE 



1*70 CELL KETTLE 

HOLE, POST- 1»Tc 

CELL 



W940W»rt> S*pt 1»* 



Figure 4: Schematic of the landfill cap, designed to prevent water leaching through the material in the landfill. 
Preventing perforations maintains its watertight integrity, hence requiring a ballasted, surface-mounted system. 



10 



The PCM Plan for the capped landfill outlined the following actions: 

• Post-closure maintenance and monitoring of the cover system is to be conducted for a minimum of 
30 years after the completion of cap construction. To verify that the cap maintains its structural 
integrity, it is inspected for animal burrows, erosion rills, settlement depressions, intrusive 
vegetation, seeps, and sedimentation in ditches and culverts. Post-closure maintenance is performed 
any time a loss of integrity is noticed; landfill inspections and land surveys are performed regularly. 

• Landfill gas and groundwater quality at the landfill are to be monitored as appropriate. The landfill 
interim remedial action will allow time to further evaluate the environmental impact of the 1947, 
1951, and 1957 cells (i.e., the NWOU cells) on groundwater quality. 

• A regular performance monitoring evaluation of the interim remedial action. 

In 1996, the EPA and MassDEP approved the closure report for the landfill capped cells, thus initiating the 
PCM plan. The Record of Decision (ROD) for the landfill was signed in October 2007 and included 
continued monitoring and maintenance of the landfill cap along with land use controls. The NWOU was 
not included in the ROD; a decision document for that area is scheduled to be completed in 2013. 

3.3 Air Installation 

The US Coast Guard now operates the airfield and control tower with limited fixed and rotary wing traffic, 
primarily USCG MH-60T Jayhawk search and rescue helicopters, and HC-144A Ocean Sentry surveillance 
aircraft and Army National Guard UH-60 Blackhawk helicopters. The airfield consists of 2 runways , 
several large aircraft parking aprons, and several hangars. 

3.4 Air Quality 

Barnstable County, Massachusetts is a nonattainment area for ozone (8-hour standard) but is in 
attainment for other criteria pollutants. The standard for particulate matter, 2.5 microns or less, will not 
be addressed for several years (Massachusetts Department of Public Health 2009). The air quality of the 
project site is unaffected by the landfill. Monitoring of the surface vents and perimeter monitoring points 
by AFCEC shows the landfill is producing no appreciable amounts of gas, including methane. 

3.5 Noise 

There are no known studies of ambient noise levels in the immediate vicinity of the project sites. 
Currently, noise at the project sites is typical of a rural setting. Sources of ambient noise include 
intermittent vehicular traffic on Connery Ave, the main gate road, vehicular traffic on abutting range 
access roads, periodic crowd noise from a bicycle motocross track adjacent to the site, weather 
disturbances, the aircraft from the USCG Cape Cod Air Station, the adjacent Army National Guard Tactical 
Training Base and natural sources (e.g., wildlife, wind). Because the surrounding areas of the project sites 
are relatively suburban, loud noises are relatively common, and ambient noise levels are likely between 
45 and 55 A-weighted decibels (dBA) under calm wind conditions. Noise from the inverters is not 
expected to affect the tactical training base due to its distance from the source. The same situation 
applies to the bicycle motocross track. 

There are no sensitive noise receptors such as schools, hospitals, or daycare centers in the immediate 
vicinity of the project sites. The nearest permanently inhabited noise-sensitive receptors are limited to 
off-base residences approximately 0.8 km (0.5 mile) to the northeast. 

11 



3.6 Base Utilities 

Otis ANGB and the MMR are fed by one primary distribution line of 12,500 kilovolt-amps (kVA), one 
standby line of the same capacity, and several smaller, isolated distribution lines to remote parts of the 
MMR. All lines are supplied with power by NStar. The primary feeder comes from off the MMR, across 
the base, and enters the base grid at the Otis ANGB 7.5 megavolt-amps (MVA) primary substation where 
the main meter is housed. From this substation, the power is distributed across the base in 5 main 
feeders which are interconnectable and, to the maximum extent practical, are metered for the primary 
tenant organization served by that feeder. Nearly all relevant lines (primary feeder to Otis as well as the 
base distribution circuits) are above ground and are owned and maintained by the 102 n IW. 

3.7 Water Resources 

The MMR is located over the Sagamore Lens which was designated as a sole source aquifer that provides 
drinking water to the residents of Upper Cape Cod. The sole source aquifer designation is in place to 
ensure that projects built on Cape Cod are designed and constructed so that they do not create a 
significant hazard to public health (EPA 1982). 

This sole-source aquifer is primarily unconfined and is recharged by infiltration of precipitation at a rate of 
approximately 30 inches per year. The groundwater flow in the landfill area is generally from east to west 
from the landfill towards Buzzards Bay (specifically Red Brook Harbor and Squeteague Harbor). 
Groundwater flow paths dip gradually, as indicated by gradually deepening contaminant plumes, into the 
aquifer instead of following a strictly horizontal flow path. This is attributed to accretion of recharge from 
precipitation at the aquifer surface rather than density differences between uncontaminated water and 
water containing dissolved chemicals. 

Prior to closing and capping, leachate from the landfill cells migrated into the groundwater forming the 
Landfill-1 (LF-1) plume. The landfill cells that contributed to the LF-1 plume included the 1970, post-1970, 
and kettle hole. The purpose of the landfill cap and associated drainage structures is to minimize the 
amount of precipitation that infiltrates the landfill and produces leachate (water containing contaminants, 
nutrients, and microorganisms) that could reach the aquifer and act as a continuing source for the LF-1 
plume. The cap has been effective at reducing the leachate that contributed to the LF-1 plume. 
Monitoring data indicate that a small portion of the LF-1 plume remains at concentrations above 
groundwater cleanup standards adjacent to the landfill source area, but the plume is disconnected from 
the source. Based on historical monitoring data and a direct push investigation completed adjacent to, 
and down gradient of, the landfill in 2007 and 2008, the landfill is no longer a significant continuing source 
for the LF-1 plume. 

The selected remedy for the LF-1 groundwater plume includes active treatment, natural attenuation, land 
use controls, and a provision to replace the Bourne Public Water Supply Wells. The active treatment is an 
extraction, treatment, and infiltration/reinjection system that began operation on 26 August 1999. It 
included five extraction wells pumping at 700 gallons per minute, an infiltration gallery, two infiltration 
trenches, and a treatment plant housing two 20,000 pound granular activated carbon units to remove the 
contaminants from the groundwater. A reinjection well was later added to supplement the infiltration 
system and a sixth extraction well was added in 2006 to capture continuation along the southern edge of 
the groundwater plume. 



12 



Based on the most recent groundwater monitoring data collected in 2012, the LF-1 plume is 
approximately 3.5 miles long, and extends from the landfill source area (in the northeast) to the west- 
southwest where the uncaptured portions of the northern and southern lobes of the plume discharge 
with groundwater to Red Brook Harbor and Squeteague Harbor, respectively. The LF-1 plume is 
approximately 4,500 feet wide and approximately 110 feet thick. The footprint of the LF-1 plume 
occupies approximately 919 acres. 

3.8 Biological Resources 

The MMR conducts an annual survey of bird species in various locations across the Reservation, including 
the grasslands of the landfill site. In the July 2012 survey, seven breeding pairs of three bird species listed 
as protected by the State of Massachusetts (but not federally listed by the US Fish and Wildlife Service) 
were found nesting on the landfill site. This discovery necessitated a habitat mitigation plan, approved by 
the Massachusetts Division of Fisheries and Wildlife, to provide alternative habitat conducive to these 
species elsewhere on the Reservation if the proposed solar array project were to proceed. 

The species of concern that were discovered nesting on the proposed site are: 

• Upland Sandpiper (Endangered) 

• Vesper Sparrow (Threatened) 

• Grasshopper Sparrow (Threatened) 

The complete list of bird species found during the July 2012 survey is provided in Table 1 below. 
There are no other protected species or species of concern inhabiting the proposed site. 
Table 1: Bird Species Inhabiting Proposed Project Location (Survey, July 20120) 



Common 
Species Code 


Species Name 


Common 
Species Code 


Species Name 


UPSA 


Upland Sandpiper (Endangered) 


COLO 


Common Loon 


GRSP 


Grasshopper Sparrow (Threatened) 


MODO 


Mourning Dove 


VESP 


Vesper Sparrow (Threatened) 


NOHA 


Northern Harrier 


AMGO 


American Goldfinch 


NOMO 


Northern Mockingbird 


AMRO 


American Robin 


RTHA 


Red-tailed Hawk 


BAOR 


Baltimore Oriole 


RWBB 


Red-winged Blackbird 


BARS 


Barn Swallow 


SASP 


Savannah Sparrow 


BHCO 


Brown-headed Cowbird 


TRES 


Tree Swallow 


CHSP 


Chipping Sparrow 


EAPH 


Eastern Phoebe 


COGR 


Common Grackle 


RSTO 


Eastern Towhee 


EABL 


Eastern Bluebird 


GBHE 


Great Blue Heron 


EAKI 


Eastern Kingbird 


KILL 


Killdeer 



13 



3.9 Cultural Resources 

There are no cultural resources remaining at the proposed project location as it is a disturbed site and has 
been since World War II. Any cultural resources that may have been in place will have been disturbed or 
destroyed decades ago. 

3.10 Geology and Soils 

In general, soils in the vicinity of MMR are sandy and permeable and permit rapid groundwater 
movement (approximately one to two feet per day). The Sagamore Lens is recharged, or replenished, by 
rainwater that seeps through the sandy soil into the aquifer. The highly permeable nature of the sands 
and gravels underlying the area allows for rapid infiltration of rainfall, which minimizes surface water 
runoff except on extreme slopes. 

The unconsolidated overburden sediment beneath MMR and adjacent areas was deposited during late- 
stage Pleistocene glaciation. The majority of the MMR and the areas to the south between the MMR 
boundary and Vineyard Sound lie within a broad glacial outwash plain referred to as the Mashpee Pitted 
Plain (MPP). The MPP is comprised of poorly graded, medium to coarse-grained sand with well-graded 
gravel, and occasional local, discontinuous lenses of fine-grained silty sands, silts, and clays. Underlying 
the MPP in most areas are silty glaciolacustrine sediments and basal till, although in some areas coarse- 
grained MPP deposits directly overlie bedrock. The landfill is located within the MPP, however the cap 
placed over the Post 1970, 1970 and the kettle hole cells is designed to be impermeable and prevent the 
infiltration of precipitation through the waste in the landfill. The cap is not representative of the soils that 
are typical to the MMR. 

3.11 Socioeconomics 

The landfill site itself is stable and requires very little maintenance or monitoring. In all, it provides less 
than one man-month of employment including testing, monitoring/inspections, technical evaluation, and 
grassland maintenance. 



14 



4.0 ENVIRONMENTAL CONSEQUENCES 

4.1 Land Use 

Proposed Action: The primary change in land use will be that the currently under-utilized capped landfill 
resource will be passively used as a productive source of up to 6 megawatts of renewable electricity. The 
principle impact within the relevant 60 acres (and the access to it) would be that the acreage may no 
longer be suitable habitat for the identified endangered bird species when the SPVS is installed and 
operated. Details of the impact to biological resources are given below in section 4.7 and in the attached 
Otis ANGB Solar Array project Grasslands Mitigation Plan. 

In addition, there will be transformer/inverter equipment installed within the site. As the SPVS will be 
surface mounted, there will be no physical change to the landfill cap itself. Installation of the array will 
still allow testing and monitoring of the landfill in accordance with AFCEC's management plan. 

Alternative Action 1: Development of an SPVS would impact greater areas (collective parcels) on 
locations on the installation that would tie up these parcels and area for 20 years within the more 
developed Otis ANGB cantonment areas that are best suited as options for any projected business or 
administrative facilities development and future core mission expansion requirements. 

Alternative Action 2: Similar issues and concerns exist with an SPVS on these parcels as noted in 
Alternative 1. This action would site the solar arrays on existing protected grassland habitat, requiring an 
environmental and habitat mitigation plan after consultation and agreement with NHESP. 

No-Action Alternative: If no action is taken, the landfill will continue as it is now - a wasted resource. Otis 
ANGB will not realize the energy cost savings through cheaper electricity and will not be able to comply 
with Energy Policy Act of 2005 and Executive Orders 13423 and 13513. 

4.2 Air Installation Compatible Use Zone 

No part of the proposed or alternative actions would employ or influence airspace operations or air traffic 
management at or around the MMR. The solar panels of the proposed action would have a non-glare 
surface and would not affect aviation activities. Construction, operation, and maintenance of the SPVS 
would not attract wildlife to the areas and thus, would not increase the bird/wildlife aircraft strike hazard. 
There would be no impact to flight safety under the proposed action. Alternative actions 1 and 2 would 
require additional analysis to determine any effects to aviation. 

4.3 Air Quality 

All the alternatives, save for the No-Action Alternative, would have a positive impact on air quality 
typically associated with renewable energy sites, and some short term negative impacts from 
construction and decommissioning (in 20 years) such as diesel fumes and dust. The landfill no longer 
releases gasses or other contaminants, so there is no air quality threat to construction or maintenance 
personnel. 

In 1993, the EPA established the General Conformity Rule which mandates that the federal government 
ensure conformity to an approved Clean Air Act implementation plan for all federally funded work and 
facilities. De minimis emissions are the total direct and indirect emissions that fall below criteria specified 
in the Rule. The EPA provides a list of actions deemed as clearly de minimis in Title 40 CFR 93.153(c)(2). 

15 



According to the Rule and Title 40 CFR 93.153(c)(2), emissions of dust during construction of the proposed 
project are considered de mimimus. The solar installation creates no other emissions once installed and 
operating. 

Under the No-Action Alternative, Otis ANGB will continue to be reliant on fossil-fuel generated electricity, 
contributing to the emission of carbon dioxide and other pollutants into the atmosphere and there would 
be no change to the status quo in relation to the General Conformity Act. 

4.4 Noise 

For the proposed action, as well as Alternative Actions 1 and 2, there would be minor noise impact during 
the construction phase to include truck and other vehicular noise on the site and along Connery Ave and 
other base roads. The solar panels themselves are silent. There will be low volume humming from the 
inverters, with a typical value from this type of equipment of 64dB at 50 feet, reducing to 40 dB at 800 
feet. This noise will be inaudible at any of the nearby activity locations. 

There is no noise impact associated with the No-Action Alternative. 

4.5 Base Utilities 

Proposed Alternative: The solar array will connect to the base grid on either the North Feeder or East 
Feeder A. It will be the contractor's responsibility to complete a full electrical survey and engineering 
plan, to be approved by the 102 n CES, for the interconnection, and must include appropriate electrical 
protection to prevent any damage from the array to the base infrastructure, and vice-versa. In the event 
of an outage of the commercial power supply, the array will automatically go off line immediately. At 
times the array may produce more power than the Otis ANGB grid demands. In those instances, the 
surplus power will feed back through the Otis transformer into the NStar distribution system. This surplus 
will be metered and Otis will receive full retail offset credit on the Hess and NStar commercial power bills. 
No utility services or facilities will be provided to the site by Otis ANGB. 

Alternative Actions 1 and 2: These actions would require the same engineering survey, interconnections, 
protection systems and inverters as the proposed solution. However, because the sites for both 
alternatives are distant from each other, they would each require either 3 or 4 times as many 
interconnections to the base grid with associated hardware, inverters, and protection systems, increasing 
the cost of the installations and reducing the economic benefit. 

No-Action Alternative: There is no impact to the base utilities with this alternative. 

4.6 Water Resources 

There will be no impact to water resources from any of the alternatives. For the Proposed and Alternative 
Actions 1 and 2, the operator may choose to wash the SPVS panels with water, but this is not required. 
The amount of water used would not be appreciable when compared to normal rainfall in the area, would 
not introduce any contaminants, and would have no impact to existing drainage patterns. The No-Action 
Alternative would have no impact on base water resources. 



16 



4.7 Biological Resources 

Proposed Alternative: The NHESP has determined that this action would result in a "take" of habitat of 
protected migratory bird species (NHESP letter included in appendix); in this case, grasslands required by 
three migratory bird species, listed by the Massachusetts NHESP as follows: 

• Upland Sandpiper (Endangered) 

• Vesper Sparrow (Threatened) 

• Grasshopper Sparrow (Threatened) 







1 





Figure 5: The Upland Sandpiper 

Listed by the Massachusetts NHESP as 
Endangered. Unusual for sandpipers, the 
Upland prefers grassland for nesting, rather 
than rocky shoreline. If approved, 
construction of the solar array will be 
postponed until after the birds have left for 
their 6,000 mile migration to Argentina. 



Figure 6: The Vesper Sparrow 

Listed by the Massachusetts NHESP as 
Threatened, the Vesper is usually the 
first species to occupy new grasslands 
such as landfills and abandoned farms. 
It breeds in northern North America and 
winters in the South and Mexico. 





Figure 7: The Grasshopper Sparrow 

Listed by the Massachusetts NHESP as 
Threatened. As its name suggests, 
grasshoppers are its primary food. 
Found all across the Eastern United 
States in the summer, and prefers the 
warm climate of the American South and 
Mexico to harsh New England winters. 



17 



Through early consultation with the NHESP, Otis ANGB and the MMR have agreed to a habitat mitigation 
plan to offset the potentially disturbed habitat (Otis ANGB Solar Project Grasslands Mitigation Plan, 
October 2012, attached). The plan commits the MMR to replacing the landfill area with additional parcels 
of land, all contiguous to existing protected grasslands habitat. As a condition of the plan, the proposed 
lease and the construction of the array will not take place between May and August, so as not to disturb 
the birds and their offspring during nesting season. 

To verify the impact to these and other bird species, the 102" IW has agreed to partner with the NHESP 
to undertake periodic wildlife studies within the project area to see what effect, if any, the presence of a 
solar array has on the breeding habits of these species. This research may affect other solar array 
installations in the state by providing more comprehensive knowledge around this kind of habitat 
disturbance, allowing for either more relaxed or more stringent, requirements for future projects. 

As per consultation with the Massachusetts DFW and the US DFW, no other migratory birds or animal 
species are known to be affected by the proposed project. 

All Other Alternative Actions: The parcels considered for this alternative are not protected and no 
protected species are known to inhabit these areas. However, in order to minimize shadowing of some of 
the panels, some trees bordering some of the sites may need to be removed. 

4.8 Cultural Resources 

As this is a previously highly-disturbed site, no impact to cultural resources is anticipated from the 
proposed action. In accordance with DoD instructions related to interactions with federally recognized 
tribes, local Wampanoag tribes of Mashpee and Aquinnah have been notified of the proposed alternative 
action by letter. The presence of cultural resources at the alternative locations is unknown and would 
require an archeological survey to confirm. 

4.9 Geology and Soils 

The installation of the array and associated construction and decommissioning activities will have no 
impact on geology or soil condition. No impact would be expected with any of the alternatives. 

4.10 Socioeconomics 

In their July 2011 feasibility study, NREL estimated that construction of the solar array will create up to 
375 local jobs. Because the array requires little maintenance, only .60 sustained jobs will be created. This 
would be the case for the Proposed and Alternative Actions 1 and 2. The No-Action Alternative would 
have no impact on the local socioeconomics. 



18 



4.11 Safety and Occupational Health 

Effects to health and safety would be minimal. Under the proposed action, there would be an increased 
construction safety risk associated with all similar construction activities on the project site and Connery 
Avenue. The proposed action is located outside all airfield clear zones and behind a security fence which 
renders it inaccessible to any non-authorized personnel. The contractor would be responsible for 
implementing a site-specific Health & Safety Plan for this project. 

Effects by the alternative proposals would be the same as described under the proposed action. 

4.12 Hazardous Materials/Waste and Solid Waste 

No use of hazardous materials is anticipated during the construction, operations, maintenance or 
decommissioning phases of either the proposed or alternative actions of this project. Use of hazardous 
materials in the manufacture and disposal of solar panels and associated equipment is minimal and safe 
disposal methods are in place within the industry. Many types of panels can be recycled reducing their 
impact on the environment at the end of their useful life. The contractor will be responsible for following 
all relevant regulations regarding the disposal of all project material at the end of the contract. 



19 



5.0 IRREVERSIBLE AND IRRETRIEVABLE COMMITMENT OF RESOURCES 

Proposed Action: An insignificant amount of irreversible resource commitments and no irretrievable 
resource commitments would be required for the proposed action. Irretrievable resources necessary to 
accomplish the proposed action would primarily be fossil fuels for transport of construction items, as well 
as for operation of heavy equipment used to construct the SPVS. However, operation of the SPVS would 
ultimately produce a renewable energy source that would negate the amount of fossil fuels used to 
construct the system. Ultimately, the renewable power generated by operation of the SPVS would more 
than counterbalance the minimal demands on non-renewable energy resources required for vehicles used 
for construction and maintenance. 

Alternative Actions 1 and 2: Resource commitment would be the same as described for the proposed 
action. 

No-Action Alternative: There would be no use of irreversible or irretrievable resources for construction 
and maintenance activities under the no-action alternative. However, the MMR would continue to use 
power generated from non-renewable resources until such time as an alternative method of acquiring 
renewable energy sources to augment the current power supply would be implemented. No action at this 
time would cause greater irreversible and irretrievable commitment of fossil fuels than would the 
proposed and alternative actions. 



6.0 CUMULATIVE IMPACTS 

Proposed Action: The primary impact to the environment would be a positive one that supports the 
Energy Policy Act of 2005 and Executive Orders 13423 and 13513 and reduces Otis ANGB's dependence 
on commercial power. Because the solar photovoltaic system would provide Otis ANGB with up to 25% of 
its power requirements, there would be a cumulative reduction in the depletion of non-renewable 
resources used to generate power over ensuing decades. 

The installation would also provide valuable data on the performance of solar power generation on Cape 
Cod, which could help inform other development projects in the region. Specifically, the US Coast Guard 
is planning to install a similar SPVS in 2013, also on the MMR. The Coast Guard will not use this power at 
the MMR but, through a net metering agreement with NStar, they will use the power to offset the utilitiy 
bills of several other Coast Guard facilities within the NStar territory. There are also three smaller SPVS 
installations very near the base that are being planned by private developers. All of these solar 
installations will substantially increase the amount of renewable energy generated on Cape Cod. This will 
lighten the electrical load on the transmission lines feeding from the mainland and could also result in 
improvements to the local environment by requiring the Sandwich Power PLant, located alongside Cape 
Cod Canal, to run less frequently. 

In economic terms, the PPA would provide Otis ANGB with a fixed, guaranteed lower price for power 
which will save the US taxpayer up to $13 million over the life of the contract. 

Because the proposed project location is within the boundaries of the MMR, quite a distance from most 
civilian activity, the impact to the local community will be minimal. Dust and noise from the construction 
is unlikely to be noticed very far from the construction site. There may be some minimal extra dust on the 

20 



roads leading to the MMR as trucks haul ballast stone and other materials to the site, but this would be a 
very small amount. 

The only two roads connecting Cape Cod and the mainland are Route 28, crossing the Cape Cod Canal in 
in the west, and Route 6, crossing the canal in the east and providing the primary trunk road to most of 
the Cape. These roads become heavily congested during the summer tourist season, primarily on 
weekends, as traffic approaches the bridges from both directions. This project would bring no additional 
truck or equipment traffic to the Cape during this busy time as construction of this project is prohibited 
during the birds' nesting season, which matches perfectly with the summer tourist season. During 
operations, the SPVS will require very little maintance so there is no long term impact to the community. 

Alternative Actions 1 and 2:. Cumulative impacts would be the same as described for the proposed 
action. 

No-Action Alternative: The no-action alternative would cause no cumulative impacts to the environment 
from construction and maintenance of an SPVS. However, until such time as use of an alternative 
renewable energy source could be developed and implemented, the non-renewable resources used to 
produce power would not be curtailed at the MMR. This would add to the increasing worldwide 
consumption of non-renewable energy resources. 



7.0 CONSULTATION AND COORDINATION 



Massachusetts Special Military Reservation Commission (SMRC) 

U.S. Fish and Wildlife Service 

Massachusetts Division of Fisheries and Wildlife 

Massachusetts National Heritage and Endangered Species Program 

Military Civilian Community Council 

Environmental Management Commission 

AFCEC MMR IRP Management Team 

MMR Energy Committee 

Joint Oversight Group (MAANG, MAARNG, USAF PAVE PAWS, and USCG) 

Massachusetts Historic Commission 

Bourne Historic Commission 

Bourne Conservation Commission 

Tribal Historic Preservation Officers - Wampanoag Tribes of Mashpee and Gay Head-Aquinnah 

Environmental Protection Agency, Region 1 

Massachusetts Department of Environmental Protection 



21 



List of Preparers 



• Captain Shawn Doyle, 102nd CES, Director of Environmental Operations, Otis ANGB 

• Rose Forbes, PE, AFCEC Installation Restoration Program, Otis ANGB 

• Thurman Deane, 102nd CES, Deputy Director of Environmental Operations, Otis ANGB 



Works Cited 

102nd CES Otis ANGB Solar Array Project Grasslands Mitigation Plan . 2012 . 

Air Force Center for Engineering and the Environment Wind Turbine Project Environmental Assessment. 2010. 

Civic SolarElectrical Noise Emissions from a Solar PV Inverter / Charger. [Online][Cited: 15 April 
2013. ]http://www.civicsolar.com/resource/lnverter-Noise-Emissions. 

Good Company.comHealth and Safety Concerns of Photovoltaic Solar 

Panels. Oregon.Gov. [Online]Unknown. http://www.oregon.gov/odot/hwy/oipp/docs/life- 

cyclehealthandsafetyconcerns.pdf. 

Lynn Haarklau2LtT. Jeffrey Henderson Final Environmental Assessment for Leasing Nellis AFB for Construction & 
Operation of a SPVS. 2006. 

Massachusetts Department of Energy Resources The Guide to Developing Solar Photovoltaics at Massachusetts 
Landfills . Yea run kown . 

National Renewable Energy Laboratory Feasability Study of Economics and Performance of Solar Photovoltaics at 
Massachusetts Military Reservation, Technical Report NREL/TP-6A20-49417. National Renewable Energy 
Laboratory (NREL). July 2011. 

Nexamp The Guide to Developing Solar Photovoltaics at Massachusetts Landfills. Unknown. 



Appendices 



• Otis ANGB Solar Project Grasslands Mitigation Plan, October 2012 

• Letter of Determination, Mass Division of Fisheries and Wildlife, dated 1 Mar 2013 

• Consultation Letters and Replies 



22 



Otis Air National Guard Base 
Solar Installation Grasslands Management Plan 



Otis Air National Guard Base 

Solar Array Project Grasslands Mitigation Plan 

October 2012 








Prepared For 

The Massachusetts Division of Fisheries & Wildlife 
Natural Heritage Endangered Species Program 
Westborough MA 01581 



Prepared By 

102" Civil Engineering Squadron 

102 nd Intelligence Wing 

Otis Air National Guard Base MA 02352 



Otis Air National Guard Base 
Solar Installation Grasslands Management Plan 



We are pleased to present this plan for the expansion and maintenance of managed grassland 
habitat, as well as the transfer of land from Otis ANGB to the Massachusetts Division of Fisheries 
and Wildlife, with respect to the planned landfill solar array project. We are firmly committed to 
maintaining sustainable operations to the greatest extent possible here at Otis ANGB. That 
commitment includes making maximum use of our land resources for both renewable energy as 
well as wildlife preservation. The two are inextricably linked here due to the type of habitat we 
have, the importance of the resident wildlife species, and our desire to maximize our clean energy 
potential. 

We would like to extend a heartfelt thanks to the Division of Fisheries and Wildlife, most 
especially the Natural Heritage and Endangered Species Program office, for their assistance in 
compiling the final plan as it reads here. This project has served to confirm the strength of our 
relationship and we look forward to working together in the future. 




Patrick J. Cobb, Colonel, MAANG 

Commander 

io2" d Intelligence Wing 



Anthony E. Schiavi, Colonel, MA ANG 

Executive Director 

Massachusetts Military Reservation 



jo2' ! " Civil Engineering Squadron, 102"" intelligence Wing, Oct 20:2 




Executive Summary 

This plan, created with the cooperation of 
the Massachusetts Department of Fisheries 
and Wildlife (the Division), Natural 
Heritage and Endangered Species Program 
(NHESP), spells out the commitments by 
the 102 11 Intelligence Wing to mitigate the 
disturbance and use of grassland habitat in 
association with a planned solar array 
installation. 



To offset the disturbed habitat, the 102 nd 

Intelligence Wing agrees to maintain the 

149 acre area known as Unit K, in its entirety, 

as grassland, according to the management Fi S ure 1: Landfl11 ' location of P lanned soIar arra y 

requirements contained herein. The 102 nd IW will add to the grassland management commitment 

33 acres of new land which is contiguous to Unit K and generally bounded by General's Blvd, 

South Outer Road, and East Inner Road. 

Additionally, the 102 nd will declare a 133 acre parcel of land to the south of the base as excess, with 
the intention of transferring ownership to the Division. This land is not used by Otis Air 
National Guard Base and is currently leased to the NHESP as part of the Crane Wildlife 
Management Area. A 54 acre portion of this land will contribute toward this mitigation plan and 
is proposed to be converted to grassland by the Division. The remainder, 79 acres of forest, 
provides higher quality habitat for other state-listed species and is therefore not proposed to be 
converted to grassland. Because of this, it will not apply to the habitat offset in this plan. 
However, the Division has agreed to hold this portion "in reserve" as a credit toward any future 
development that may disrupt similar habitat. 

This plan will remain in place for the duration of the 20-year solar array power purchase 
agreement. At that point both the solar array installation and this plan will be re-evaluated for 
further action. 



Otis Air National Guard Base 
Solar Installation Grasslands Management Plan 



Table of Contents 

Executive Summary 

1. Solar Array Installation Project 

Background and Description 

Justification 

Timeline 

2. Landfill Area 2 

Description 2 

Solar Array Installation Areas 2 

Species Concerned 3 

3. Mitigation Offset Plan 4 

Overview 4 

Landfill Solar Array Site 4 

UnitK 4 

Current State of Unit K 4 

Current Grasslands Management Commitments 5 

Plan for Conversion to Grassland 6 

New Land Contiguous to Unit K 6 

Tract 5 6 

4. Lifespan of this Agreement 8 

Appendix I 



102" Civil Engineering Squadron, 102" Intelligence Wing, Oct 2012 



Otis Air National Guard Base 
Solar Installation Grasslands Management Plan 



1. Solar Array Installation Project 

Background and Description 

The 102 nd Intelligence Wing is pursuing a project to install a 4-6 Megawatt solar array on a former 
landfill site. The entire infrastructure of the array will be owned and operated by a third party 
supplier who will sell the energy produced to the 102" IW through a Power Purchase Agreement 
(PPA). 

The landfill site has been determined to be an excellent location for a solar project by the 
National Renewable Energy Laboratory. Due to its being a capped, managed landfill, the land has 
little value for other purposes. Because maintaining the integrity of the cap is crucial, the solar 
array will be surface mounted with no ground penetrations of any kind. 

The life of the contract will be 20 years, after which the contract and condition of the hardware 
will be re-evaluated to either terminate the agreement or extend it. Upon termination, all solar 
panels, mounting hardware and supporting infrastructure will be removed and the land restored 
to grassland habitat subject to review and approval by the Massachusetts Division of Fisheries and 
Wildlife (the Division). 

Justification 

A preliminary economic analysis of the PPA shows a potential renewable energy gain of 123 MWh 
and an energy bill savings of up to $6.8 Million over the 20 year life of the project. Even given a 
worst case scenario of no growth in conventional utility prices, a 2% increase in solar power cost 
per year, and an increase in interest rates to 8%, the PPA could still return up to $4.9 Million. 

Timeline 

The project was originally to due to start construction in March 2013, with the array producing 
revenue generating power by July of that year. Adding time for this mitigation plan to be created, 
and recognizing the potential for threatened or endangered species to be nesting during our 
planned construction time, the construction timeline will be postponed until September 2013 or 
until there is no risk of disturbing nesting birds. 



102" Civil Engineering Squadron, 102" Intelligence Wing, Oct 2012 



Otis Air National Guard Base 
Solar Installation Grasslands Management Plan 



2. Landfill Area 



Description 

The landfill area is a 66 acre plot of land in a secure part of the Massachusetts Military 
Reservation that was used as a general landfill from the 1940s to the 1970s. Since 1995, it has been 
capped off and managed by the Air Force Civil Engineering Center (AFCEC), which continues to 
maintain responsibility for its management. The capped area is grassland consisting mostly of 
gentle slopes and large, relatively flat areas. 

Solar Array Installation Areas 

The solar array will be built on the grassy areas shown in Figure 2. The forested area is not related 
to the project. For reference purposes, the plot has been divided into areas referred to as Sites 1, 2 
and 3. 




Figure 2: Sites of Proposed Solar Array Installation 



nd 



102" Civil Engineering Squadron, 102" Intelligence Wing, Oct 2012 



Otis Air National Guard Base 
Solar Installation Grasslands Management Plan 



Species Concerned 

Following is a list of all bird species found in the landfill site during the 26 June 2012 bird survey. 
The species at issue are the endangered Upland Sandpiper, and the threatened Vesper Sparrow 
and Grasshopper Sparrow. 



Common 

Species 

Code 


Species Name 


UPSA 


Upland Sandpiper 


(Endangered) 


GRSP 


Grasshopper Sparrow 


(Threatened) 


VESP 


Vesper Sparrow 


(Threatened) 


AMGO 


American Goldfinch 




AMRO 


American Robin 


BAOR 


Baltimore Oriole 




BARS 


Barn Swallow 




BHCO 


Brown-headed Cowbird 




CHSP 


Chipping Sparrow 


COGR 


Common Grackle 


EABL 


Eastern Bluebird 


EAKI 


Eastern Kingbird 


EAPH 


Eastern Phoebe 




RSTO 


Eastern Towhee 




GBHE 


Great Blue Heron 




KILL 


Killdeer 




COLO 


Common Loon 




MODO 


Mourning Dove 




NOHA 


Northern Harrier 




NOMO 


Northern Mockingbird 




RTHA 


Red-tailed Hawk 




RWBB 


Red-winged Blackbird 




SASP 


Savannah Sparrow 




TRES 


Tree Swallow 



nd 



102" Civil Engineering Squadron, 102" Intelligence Wing, Oct 2012 



Otis Air National Guard Base 
Solar Installation Grasslands Management Plan 



3. Mitigation Offset Plan 



Overview 

Installation of the solar array potentially disrupts habitat conducive to the species mentioned 
above, resulting in a prohibited "TAKE" of the state-listed grassland bird species. Because of this, 
alternative suitable land must be designated and converted so as to replicate the existing 
grassland habitat. Through agreement between the 102" IW and the Division, the 102 11 IW 
commits to maintain designated grassland habitat in accordance with the OANGB Grassland 
Management Plan, 2002 (Revised 2008). The relevant excerpt from this plan is attached as an 
appendix. 

The following parcels of land are designated as managed grassland habitat: 

Landfill Solar Array Site 

The solar array installation may not require all of the grassland of the landfill. Remaining 
grassland on the perimeter and between the rows of solar panels may still be suitable habitat. The 
102 11 IW will maintain these perimeter and inter-row areas in accordance with the grassland 
requirements as laid out in this plan. 

UnitK 

In accordance with the OANGB Integrated Natural Resources Management Plan, December 2007, 
(INRMP) the 102" IW is committed to maintaining Unit K as a grassland (Figure 3). To date, part 
of Unit K has been managed as such, but not the entire parcel. As part of this plan, the 102 nd IW 
commits to converting and maintaining the entire Unit K area in accordance with the INRMP. 

Current State of Unit K 

Unit K is currently in an intermediate state consisting of cultural grassland, managed 
grassland, and transitional (treed) grassland. There are remnant impervious surfaces 
scattered throughout the area. This material, up to 14 acres, is scheduled to be removed. 
The area is dominated by grass species including filiform fescue (Festuca tenuifolia), little 
bluestem (Schizachyrium scoparium), switchgrass (Panicum virgatum), hairgrass 
(Deschampsia flexuosa), redtop (Agrostis gigantea), poverty grass (Danthonia spiccata), 
and Pennsylvania sedge (Carex pennsylvanica). The only common tree species are 
immature pitch pine and red cedar. Sweetfern (Comptonia peregrina) was found in dense 
thickets less than a meter in height, whereas bayberry (Myrica pensylavanica), blueberry, 
and scrub oak were present, but less common. Many non native and invasive species such 
as honeysuckle (Lonicera spp.), Asiatic bittersweet (Celastrus orbiculata), autumn olive 
(Elaeagnus umbellata), and spotted knapweed (Centaurea maculosa) occur in this 
grassland area. 



102" Civil Engineering Squadron, 102" Intelligence Wing, Oct 2012 



Otis Air National Guard Base 
Solar Installation Grasslands Management Plan 




Figure 3: Aerial view showing Unit K as well as 33 acres of new land, Areas A and B, to the southeast. 

Current Grasslands Management Commitments 

Below is a summary of the commitments the 102 n IW has in relation to Unit K, as per the 
OANGB Integrated Natural Resources Management Plan, December 2007: 

7.4.11 Unit K - Grassland Unit 

1. Maintain all grassland areas outside the airfield fence in order to provide 
habitat for state-listed bird species and prevent areas from returning to 
forested lands. 

2. Mowing to be accomplished IAW the Grasslands Management Plan 02, 
including but not limited to, not mowing the area during the period May 1 - 
July 31 of each year. 

3. Clear grassland areas that are slowly succeeding to forest. Seed with native 
grasses and 



nd 



102" Civil Engineering Squadron, 102" Intelligence Wing, Oct 2012 



Otis Air National Guard Base 
Solar Installation Grasslands Management Plan 

4. Maintain as grasslands LAW the Grasslands Management Plan 02, in order 
to provide habitat for state-listed bird species and prevent areas from 
returning to forested lands. 

5. Particularly in Unit K, consider use of controlled burns for grassland 
management. 



Plan for Conversion to Grassland 

The parcel has great baseline condition as a grassland area. Mechanical removal of trees, 
mowing, and prescribed fire are used in current maintenance activities as well as 
monitoring and removal of invasive species as practical. An increase in frequency of these 
management techniques would lead to a well managed grassland area. The 102 nd I W will 
procure funding and resources to restore the entire Unit K area to the condition required 
above. 

New Land Contiguous to Unit K 

The 102 nd IW will commit a new 33 acre parcel of land, contiguous to Unit K to the southeast, to 
be designated as grassland and managed as stated above (Figure 3). The land is nearly flat and is 
currently maintained to grassland standard. 

Tract 5 

Tract 5, as defined in the lease between the Special Military Reservation Commission (SMRC) and 
the Division, is a plot of land to the south of OANGB abutting the Crane Wildlife area (Figure 4). 
It is currently under a 20 year lease to the Division, due to expire in 2019. As part of this plan, 
OANGB will declare this parcel surplus to the SMRC, proposing that ownership transfer to the 
Division, thereby giving up all rights to it in perpetuity with one proviso. The area relevant to this 
project is the 54 acre eastern portion bounded on the north by Kittredge Road, on the west by 
Turpentine Road and to the south by Crane Wildlife Area. Kittredge Road itself will remain the 
property of OANGB. 



102" Civil Engineering Squadron, 102" Intelligence Wing, Oct 2012 



Otis Air National Guard Base 
Solar Installation Grasslands Management Plan 




Figure 4: Tract 5. Section 5A is to be banked as credit toward future development on similar habitat. Section 
5B is part of this mitigation plan. 



The western 79 acre triangular section of Tract 5 is included in the handover of ownership but is 
not a part of this mitigation plan because it is unsuitable for conversion to grassland. However, 
the 102 nd expressed an interest in declaring the entire parcel surplus rather than subdividing it. 
The Division agreed to hold this land "in reserve" to be credited toward any future development 
plans affecting state-listed species for which the habitat at the time is a suitable mitigation. This 
area is bounded by Crane Wildlife Area, the railroad track, and Turpentine Road. 



nd 



102" Civil Engineering Squadron, 102" Intelligence Wing, Oct 2012 



Otis Air National Guard Base 
Solar Installation Grasslands Management Plan 

The proviso to the handover of Tract 5 is that access to the monitoring wells owned by AFCEC 
and the US Geological Survey will remain unimpeded as long as required by those two agencies 
(Figure 5). 




Figure 5: Tract 5 showing locations of sampling wells managed by AFCEC and USGS. Access to these wells will 
be maintained as long as required by the owning agencies. 



4. Lifespan of this Agreement 

This agreement shall be valid for the 20 year life of the solar array PPA installation, except for the 
transfer of ownership of Tract 5, which is in perpetuity. At the end of the contract period the PPA 
and array will be re-evaluated to decide whether to terminate the contract and return the ground 
to its previous condition or to take some other action deemed appropriate at that time. The re- 
evaluation of this plan, in cooperation with the Division, will be part of that activity. Any land 
restoration plans will have to be approved by the Division. 



nd 



102" Civil Engineering Squadron, 102" Intelligence Wing, Oct 2012 



Otis Air National Guard Base 
Solar Installation Grasslands Management Plan 



Appendix 

Excerpt from the OANGB Grassland Management Plan 2002 (revised 2008), denning the 
requirements of OANGB managed grasslands: 

5 .0 MANAGEMENT PLAN FOR MANAGED GRASSLAND AREA 

5.1 RESTORATION ACTIVITIES 

The primary goal of the Otis ANGB Grasslands Management Plan is to restore that portion 
of the grassland area on Otis which has become overgrown to its early successional state. 

This area of approximately 161.57 acres is bounded: on the east by Generals Boulevard; on the 
west by West Inner Road; on the south by South Inner Road; and on the north by Richardson 
Road. 

It is expected that it will take several years to bring this area back to an early successional 
state. ... 

5.2 MANAGEMENT AND MAINTENANCE ACTIVITIES 



To successfully manage these areas, the following provisions will apply to the Managed 
Grassland Area: 

a. All activities and land uses are normally restricted from this area. 

b. Restricted activities include the following: 

1) Mowing between May i$t and July 31 $t of each year (to accommodate the period of 
nesting and brood-rearing by the state-listed grassland birds) 

2) Vehicle traffic in areas other than established roads( excluding activity by 
personnel associated with management of the area) 

3) Foot traffic in areas other than established roads (excluding activity by personnel 
associated with management of the area) 

4) Camping or bivouacking(This would not preclude setting up military equipment in 
the area (such as temporary communications towers) without actual 

camping /bivouacking of personnel.) 

5) Recreational activities, including team sports that require playing fields 

102" Civil Engineering Squadron, 102" Intelligence Wing, Oct 2012 



Otis Air National Guard Base II 
Solar Installation Grasslands Management Plan 

c. The grasslands should be maintained by periodic mowing or burning either before Mayi st 
or after July 31 st (the breeding season for grassland birds). 

d. The grass in the managed grassland area should be mowed to a height of 14 inches. 

e. One-half of the area should be mowed each year to provide vegetation cover of varying 
heights; and burned every three or four years to reduce the amount of underbrush growth 
accumulated on the ground. 

NOTE: The periodic burning and mowing of the managed grassland area will serve to 
maintain the ecosystem by preventing colonization by trees and shrubs. 

f Regular mowing of 20 - 50 ft wide strips along roads in this area may occur throughout the 
year. 

g. Non-native plants (e.g., Asiatic bittersweet, multiflora rose, Japanese Honeysuckle) within 
the Managed Grassland area will be eradicated when possible and within available federally- 
provided resources by current best management practices including, but not limited to, 
stump and paint application of herbicide and mechanical removal. 

h. Fragmentation of the managed grasslands area, which reduces the probability of 
attracting grassland birds (particularly highly area-sensitive species such as the Upland 
Sandpiper) will be avoided. When possible and within available federally-provided resources, 
the sources of frag mentation (e.g., roads, groves of trees, hedgerows) should be removed. 
Hedgerows dominated by woody vegetation taller than 10 ft (3 m) or wider than 16 feet (5 m) 
will also be removed when possible. 

i. This area will be managed to provide a diversity of grassland habitats. 

j. When managed grasslands habitat on Otis ANGB border a forested habitat, a more 
natural, open or "feathered" edge between grassland and forest will be encouraged, rather 
than maintaining sharp, straight contrasting walls of woody vegetation. 

k. If mowing needs to be accomplished to accommodate parking for air shows or for other 
military mission needs: 

1) Concentrate the mowing outside of the mid-May to mid-July timeframe, the peak 
nesting period for the majority of grassland breeding birds. 

2) Walk the area to be mowed to identify any specific nests, roping off a safe area 
around any nests. The roped-off area will remain unmowed. Place an appropriate off- 
limits sign at the roped-off area. 



102" Civil Engineering Squadron, 102" Intelligence Wing, Oct 2012 



Otis Air National Guard Base III 
Solar Installation Grasslands Management Plan 

3) Use an annual rotational mowing system in which some sections are left un- 
mowed each year; as a mowing cycle 0/3 to 5 years (depending on site conditions) is 
beneficial especially for species that need bushes or short trees for perches. 

4) Use a cutting height of 3 - 5 inches for safety purposes. 

5) Favor early spring mowing (March, early April) over late Summer-fall (August- 
October) mowing to provide winter habitat for grassland birds (e.g., Northern 
Bobwhite, Northern Harrier, Short-eared Owl). This will allow time for regrowth and 
seed production. 

NOTE: It is the standard policy of the 102" Intelligence Wing not schedule air shows 
between the May 1st through July 31st timeframe. 

I. Use native warm-season grasses which grow during the summer rather than grasses which 
grow during the cooler spring and fall months. (Warm-season grasses grow in clumps each 
surrounded by relatively open areas that provide a network of travel lanes for birds; whereas 
cold-season grasses form more uniformly dense stands, leaving little room for birds to move 
about.) 

m. Following are recommendations regarding management of native warm-season grasses: 

1) Monotypic stands do not provide adequate habitat for birds, especially in the form 
ofvegetative structure. It is more beneficial to plant a mixture of tall and short 
grasses, which result in a mosaic ofvegetative heights. 

a) Recommended tall grasses include: big bluestem, Indian grass, switch 
grass, and side-oats gama. 

b) Recommended short grasses include little bluestem and broomsedge. 
Because native warm-season grasses vary in soil and moisture requirements, 
some of the grasses will become dominant in some fields, or parts of larger 
fields, and other grasses in other fields or parts of fields, depending on soil 
moisture and fertility. As a result, the habitat will become more diverse and 
of greater benefit to birds. To further increase the diversity of the vegetation, 
native forbs can be encouraged (e.g., Butterfly Weed). These will help attract 
insects, which are a vital protein source for growing nestlings. 

a) Of these three practices, prescribed bums generally provide the most 
benefit to grassland bird communities. Burns should be conducted in early 
spring (March-early April) or late fall (October- November). In grasslands 
larger than 100 acres (40 ha), prescribed burns should be conducted on an 
annual rotation in which 20-30 percent of the total grassland area is burned 

i02 n Civil Engineering Squadron, 102" Intelligence Wing, Oct 2012 



Otis Air National Guard Base IV 
Solar Installation Grasslands Management Plan 

during a single year. On smaller grasslands, annual burns may represent a 
larger percentage of the total grassland area, but should not exceed 50-60 
percent. Light grazing (leaving more than 40 percent of vegetation over lOin, 
or 25 cm, tall) or moderate grazing (leaving 20-40 percent of vegetation over 
10 inches tall) can benefit grassland birds and help maintain native warm- 
season grass communities. The best practice is to use a rotational system in 
which some sections are lightly grazed while others are left idle. 

D. Tall trees (more than 10ft, or 3 m, in height) and snags should be removed from the parts 
of the managed grasslands that are more than 300 feet (go m)from the grassland edge. If 
not removed, these structures may provide observation perches for avian nest predators or 
for Brown-headed Cowbirds scouting for host-species' nests to parasitize. However, a few 
scattered small trees throughout the area can improve habitat for species such as Field 
Sparrows and American Kestrels. Within a regional context, it is probably best to provide a 
diversity of grassland habitats, ranging from prairie-like areas free of woody vegetation to 
lightly treed, savannah-like grasslands. 

o. Human disturbances to the managed grasslands will be minimized, especially during the 
nesting season. 

p. Garbage and trash collection facilities and containers will be kept away from the managed 
grasslands area as they can attract unwanted concentrations of predators. 

q. Modification or amendments to these procedures for the managed grassland area will be 
made as needed and appropriate. 



102" Civil Engineering Squadron, 102" Intelligence Wing, Oct 2012 




04/25/2013 12:36 FftK SI? 727 5128 MASS HIST COMM 1 002/003 

DEPARTMENT OF THE AIR FORCE ^ 

102D INTELLIGENCE WING (ACQ MAGG UWT rfiMMf 

MASSACHUSETTS AIR NATIONAL GUARD MASS. HIS I, VUMM 

OTIS AIR NATIONAL GUARD BASE MASSACHUSETTS . 

27 March 2013 

102CES/CE 

971 South Outer Road 

Otis ANG Base MA 025-12-1330 

Massachusetts Historical Commission 
ATTN: Ms. Brona Simon 
220 Morrissey Boulevard 
Boston MA 02125 

SUBJECT: Proj ect Notification for a Landfill Solar Array at the Massachusetts Military 
Reservation (MMR), MA 

I 
Dear Ms. Simon: 

The 102 Intelligence Wing (1 02 Ed IW) located at Otis Air National Guard (ANG) Base at 
the Massachusetts Military Reservation (MMR) on Cape Cod, MA is propos ing to construct and 
operate up to a six megawatt (6 MW) sola: array on the closed base landfill. The solar array 
project will be awarded to a soiar developer under a power purchase agreement. The power _ 
produced by the solar array will be used by the Otis ANG Base to offset the power consumption, 
and associated air emissions, of the 102 IW mission. The 1 02 nd IW respectfully requests a > 
review of this proposed project by the Massachusetts Historical Commission. A bnef description 
of the project scope and location is attached. 

k feasibility study (FS), which was funded by the Environmental Protection Agency and 
describes the basic project proposal, was conducted by the National ^f^^?gJ^L 
(NRH/i for this project and is available at burn:// www, nrel . gov/doca/fy 1 1 osti/494 1 7.p d t A He 
solar array project is proposed for the former base landfill which is located on Connery Avenue 
in the town of Bourne, MA on MMR. The portion of the landfill under consideration Tor the 
solar array consists of approximately 60 acres which was capped m 1995: The landfill is a 
regulated site under the Comprehensive Environmental Response, Compensation, and Liability 
Act (CERCI A) and is managed by the Air Force Civil Engineer Center (AFCEC). The area 
proposed for the solar array has been previously disturbed through the use as a landfill, which 
was subsequently capped. As part of post closure requirements, a vegetative surface is 
maintained on the cap to prevent erosion and encourage evaporranspiration. ■ The cap is mowed 
once a year to prevent tree and/or shrub growth. Trees and/or shrubs are not desired on the ■ 
landfill as their root systems could impact the integrity of the cap. 

As discussed in the NREL FS, the array installation will include ballasted solar panels to 
prevent impacts to the integrity of the landfill cap, similar to other solar arrays installed on 
landfill caps . The Massachusetts Department of Environmental Protection (MassDEP) 



M13 



0.1/25/2013 12:38 Pi 



B17 72 7 5128 



MASS HIST COMI 



lg] 003/003 



encourages the post-closure use of landfills for renewable energy projects as long as the use will 
not compromise the environmental protection afforded by the landfill cap and closure. MassDEP 
has developed guidance including a fact sheet entitled; "Developing Renewable Energy Facilities 
on Closed Landfills" which is available at httn ://w ww.mass. gov/dep/e nersv /landfilLhtm . _ 

Thank you for your assistance. We would appreciate a response by 10 April 2013 if you 
have any questions regarding the proposed project or the enclosed materials. Please contact me 
■at 508-968-4960; email shawn.doyle@ang.af.mil. 



Attachment: 

Otis ANCrB Solar Array Project Brief 



Sincerely, 



xf^UvVL 



SHAWN W. DOYLE, Capt, MA ANG 
Chief, Environmental Management 



After review of MHC's files and the materials 
you submitted, it has been determined that 

this project is unlikely to affect significant 
historic or archaeological resources. 




Edward L, Bell a&/^ 1. 2© r$ Date 

Deputy State Historic Preservation Officer 
Massachusetts Historical Commission 



M13 




DEPARTMENT OF THE AIR FORCE 

102D INTELLIGENCE WING (ACC) 

MASSACHUSETTS AIR NATIONAL GUARD 

OTIS AIR NATIONAL GUARD BASE MASSACHUSETTS 



18Mar2013 



102 CES/CEV 

971 South Outer Road 

Otis ANG Base MA 02542 

Mr. Thomas R. Chapman 

Supervisor 

New England Field Office 

U.S. Fish and Wildlife Service 

U.S. Department of the Interior 

70 Commercial Street Suite 300 

Concord, NH 03301-5087 



Subject: Project Review Request for a Landfill Solar Array at the Massachusetts Military 
Reservation (MMR), MA 



Dear Mr. Chapman: 

The 102 Intelligence Wing (102 nd IW) located at Otis Air National Guard (ANG) Base at the 
Massachusetts Military Reservation (MMR) on Cape Cod, MA is proposing to construct and operate 
up to a six megawatt (6 MW) solar array on the closed base landfill. The solar array project will be 
awarded to a solar developer under a power purchase agreement. The power produced by the solar 
array will be used by the Otis ANG base to offset the power consumption, and associated air 
emissions, of the 102 IW mission. 

The 102 n<1 IW respectfully requests a review of this proposed project by the U.S. Fish and 
Wildlife Service for potential impacts to, or concerns regarding, federally-listed endangered and 
threatened species and their habitats on or in the vicinity of the proposed project site. The MA 
Army National Guard Natural Resources Office has conducted annual bird surveys at the landfill 
over the past several years. No federally recognized threatened or endangered species have been 
identified at the landfill; however, three state listed threatened and endangered bird species have 
been identified. Due to the presence of the state listed species, a consult with the Massachusetts 
Natural Heritage and Endangered Species Program (MANIIESP) was initiated and has been 
completed (Attachment 1). 

A feasibility study (FS), funded by the Environmental Protection Agency, was conducted by 
the National Renewable Energy Lab (NREL) for this project and is available at 
htm:.' .'www.rtfel.gov/docs/ryl losti/4941 7.pdf . The solar array project is proposed for the former 



D12 



base landfill which is located on Connery Avenue in the town of Bourne, MA on MMR. The 
portion of the landfill under consideration for the solar array consists of approximately 60 acres 
which was capped in 1995. The landfill is a regulated site under the Comprehensive 
Environmental Response. Compensation, and Liability Act (CERCLA) and is managed by the 
Air Force Civil Engineer Center (AFCEC), The area proposed for the solar array has been 
previously disturbed through the use as a landfill, which was subsequently capped. As part of 
post closure requirements, a vegetative surface is maintained on the cap to prevent erosion and 
encourage evapotranspiralion. The cap is mowed once a year to prevent tree and/or shrub 
growth. Trees and/or shrubs are not desired on the landfill as their root systems could impact the 
integrity of the cap. 

As discussed in the NREL FS, the array installation will include ballasted solar panels to 
prevent impacts to the integrity of the landfill cap, similar to other solar arrays installed on 
landfill caps. The Massachusetts Department of Environmental Protection (MassDEP) 
encourages the post-closure use of landfills for renewable energy projects as long as the use will 
not compromise the environmental protection afforded by the landfill cap and closure. MassDEP 
has developed guidance including a fact sheet entitled; "Developing Renewable Energy Facilities 
on Closed Landfills" which is available at http://www.mass.gov/dep/energy/landfill.htm . 

Thank you for your assistance. If you have any questions regarding the proposed project 
or the enclosed materials please contact me at (508) 968-4960 or at email 
shawn.doyle@ang.af.mil. 




Y[ 



{Akip&H$ 



Shawn W. Doyle, Capt 
Massachusetts Air National Guard 
Chief, Environmental Management 
102 nd CES/CEV 



Attachment: 

MANHESP Project Review and Take Letter 



D12 




United States Department of the Interior 

FISH AND WILDLIFE SERVICE 

New England Field Office 
70 Commercial Street, Suite 300 

Concord, NH 03301-5087 
http://www.rws.gov/newengland 



U.S. ^ 

fish * wir.ni.rKi-: 
service; 




Reference: Project 

Landfill solar array project 



April 24, 2013 

Location 

Massachusetts Military Reservation, Bourne, MA 



Shawn W. Doyle, Captain 
Massachusetts Air National Guard 
102D Intelligence Wing (ACC) 
Otis Air National Guard Base, MA 02542 



Dear Captain Doyle: 

This responds to your recent correspondence requesting information on the presence of federally 
listed and/or proposed endangered or threatened species in relation to the proposed activity 
referenced above. These comments are provided in accordance with the Endangered Species Act (87 
Stat. 884, as amended; 16 U.S.C. 1531, et seq.). 

Based on information currently available to us, no federally listed or proposed, threatened or 
endangered species or critical habitat under the jurisdiction of the U.S. Fish and Wildlife Service are 
known to occur in the project area. Preparation of a Biological Assessment or further consultation 
with us under section 7 of the Endangered Species Act is not required. No further Endangered 
Species Act coordination is necessary for a period of one year from the date of this letter, unless 
additional information on listed or proposed species becomes available. 

To obtain updated lists of federally listed or proposed threatened or endangered species and critical 
habitats, it is not necessary to contact this office. Instead, please visit the Endangered Species 
Consultation page on the New England Field Office's website: 

www.fws.gov/newengIand/endangeredspec~comultation.htm (accessed January 2013) 

On the website, there is also a link to procedures that may allow you to conclude if habitat for a listed 
species is present in the project area. If no such habitat exists, then no federally listed species are 
present in the project area and there is no need to contact us for further consultation. If the above 
conclusion cannot be reached, further consultation with this office is advised. Information 
describing the nature and location of the proposed activity that should be provided to us for further 
informal consultation can be found at the above-referenced site. 



Shawn W. Doyle, Captain 
April 24, 2013 



Thank you for your coordination. Please contact Brett Hillman of this office at 603-223-2541, 
extension 34, if we can be of further assistance. 

Sincerely yours, 



r 



yvpt 



Thomas R. Chapman 

Supervisor 

New England Field Office 




DEPARTMENT OF THE AIR FORCE 

102D INTELLIGENCE WING (ACC) 

MASSACHUSETTS AIR NATIONAL GUARD 

OTIS AIR NATIONAL GUARD BASE MASSACHUSETTS 



27 March 2013 

102CES/CEV 

971 South Outer Road 

Otis ANG Base MA 02542-1330 

Mr. Chuck Green 

Tribal Historic Preservation Officer 

766 Falmouth Road 

UnitA7 

PO Box 1048 

Mashpee, MA 02649 

SUBJECT: Project Notification for a Landfill Solar Array at the Massachusetts Military 
Reservation (MMR), MA 

Dear Mr, Green: 

The 102 Intelligence Wing (102 nd IW) located at Otis Air National Guard (ANG) Base at the 
Massachusetts Military Reservation (MMR) on Cape Cod. MA is proposing to construct and 
operate up to a six megawatt (6 MW) solar array within your Tribe's ancestral homelands. The 
solar array project is proposed for the closed and capped base landfill and will be awarded to a solar 
developer under a power purchase agreement. The power produced by the solar array will be used 
by the Otis ANG Base to offset the power consumption, and associated air emissions, of the 102 IW 
mission. A description of the project scope and location is attached. 

A feasibility study (FS), funded by the Environmental Protection Agency, was conducted by 
the National Renewable Energy Lab (NREL) for this project and is available at 
http://www.nrel.gov/docs/ry 1 i osti/4941 7.pdf . The solar array project is proposed for the former 
base landfill which is located on Connery Avenue in the town of Bourne, MA on MMR. The 
portion of the landfill under consideration for the solar array consists of approximately 60 acres 
which was capped in 1995. The landfill is a regulated site under the Comprehensive Environmental 
Response, Compensation, and Liability Act (CERCLA) and is managed by the Air Force Civil 
Engineer Center (AFCEC). The area proposed for the solar array has been previously disturbed 
through the use as a landfill, which was subsequently capped. As part of post closure requirements, 
a vegetative surface is maintained on the cap to prevent erosion and encourage evapotranspiration. 
The cap is mowed once a year to prevent tree and/or shrub growth. Trees and/or shrubs are not 
desired on the landfill as their root systems could impact the integrity of the cap. 

As discussed in the NREL FS, the array installation will include surface-mounted, ballasted 
solar panels to prevent impacts to the integrity of the landfill cap, similar to other solar arrays 
installed on landfill caps. The Massachusetts Department of Environmental Protection (MassDEP) 
encourages the post-closure use of landfills for renewable energy projects as long as the use will not 
compromise the environmental protection afforded by the landfill cap and closure. MassDEP has 



M13 



developed guidance including a fact sheet entitled; "Developing Renewable Energy Facilities on 

Closed Landfills" which is available at bttp:// w wvv. mass. gov/dep/energy/landfi 1 1 .htm . 

Please let us know by 10 April 2013 if you have any interests or concerns regarding this 
project as related to cultural resources of your Tribe. Your response will aid the 102 n IW at Otis 
ANG Base in complying with Section 1 06 of the National Historic Preservation Act of 1966, as 
amended. 

Thank you for your assistance. If you have any questions regarding the proposed project or 
the enclosed materials, please contact me at 508-968-4960; email shawn.doyle@ang.af.mil. 



Sincerely, 




SHAWN W. DOYLE, Capt, MA ANG 
Chief, Environmental Management 



Attachment: 

Otis ANGB Solar Array Project Brief 



M13 




Mashpee Wampanoag Tribe 

483 Great Neck Rd. South 
Mashpee, MA 02649 

Tribal Historic Preservation Department 



*Rl*?> 



Shawn W. Doyle, Capt, MA ANG 

Chief, Environmental Management 

102CES/CEV 

971 South Outer Road 

OtisANGBaseMA 02542-1330 

April 25, 2013 

RE: Project Notification for a Landfill Solar Array at the Massachusetts Military 
Reservation (MMR), MA 



Dear Capt. Doyle, 

I'm writing in response to your letter dated March 27, 2013 requesting Section 106 
Review and comments related to the Solar Array project proposed for the MMR. Thank 
you for providing the map and full description of the project. Based on that information 
it is agreed that we have no cultural or historic interest in the site, because it is situated 
upon previously disturbed soils. Using the former landfill cap is an excellent recycle 
land-use plan in itself. 

The Air National Guard is developing an ecological good neighbor reputation with the 
Tribe. Good luck with the solar array, we hope it yields all the power needed to offset the 
Otis ANG Base. 



In Thanksgiving, **~- y / -- n 

Ramona Peters 

Mashpee Wampanoag Tribal Historic Preservation Officer 



THPO Office 766 Falmouth Road, Suite A3 Mashpee, MA 02649 (508) 477-6186 roctenffltawtribexoiii 




DEPARTMENT OF THE AIR FORCE 

I02D INTELLIGENCE WING (ACC) 

MASSACHUSETTS AIR NATIONAL GUARD 

OTIS AIR NATIONAL GUARD BASE MASSACHUSETTS 



27 March 2013 

102CES/CE 

971 South Outer Road 

Otis ANG Base MA 02542-1330 

Ms. Bettina Washington 

Tribal Historic Preservation Officer 

Wampanoag Tribe of Gay Head - Aquinnah 

20 Black Brook Road 

Aquinnah MA 02535 

SUBJECT: Project Notification for a Landfill Solar Array at the Massachusetts Military 
Reservation (MMR), MA 

Dear Ms. Washington: 

The 102 Intelligence Wing (102 nd IW) located at Otis Air National Guard (ANG) Base at 
the Massachusetts Military Reservation (MMR) on Cape Cod, MA is proposing to construct and 
operate up to a six megawatt (6 MW) solar array within your Tribe's ancestral homelands. The 
solar array project is proposed for the closed and capped base landfill and will be awarded to a 
solar developer under a power purchase agreement. The power produced by the solar array will 
be used by the Otis ANG Base to offset the power consumption, and associated air emissions, of 
the 102 IW mission. A description of the project scope and location is attached. 

A feasibility study (FS), funded by the Environmental Protection Agency, was conducted 
by the National Renewable Energy Lab (NREL) for this project and is available at 
hnp: "wv\\v.nrel.gov.docs.'fvUosti/4941 7.pdf . The solar array project is proposed for the former 
base landfill which is located on Connery Avenue in the town of Bourne, MA on MMR. The 
portion of the landfill under consideration for the solar array consists of approximately 60 acres 
which was capped in 1 995. The landfill is a regulated site under the Comprehensive 
Environmental Response, Compensation, and Liability Act (CERCLA) and is managed by the 
Air Force Civil Engineer Center (AFCEC). The area proposed for the solar array has been 
previously disturbed through the use as a landfill, which was subsequently capped. As part of 
post closure requirements, a vegetative surface is maintained on the cap to prevent erosion and 
encourage evapotranspiration. The cap is mowed once a year to prevent tree and/or shrub 
growth. Trees and/or shrubs are not desired on the landfill as their root systems could impact the 
integrity of the cap. 

As discussed in the NREL FS, the array installation will include ballasted solar panels to 
prevent impacts to the integrity of the landfill cap, similar to other solar arrays installed on 
landfill caps. The Massachusetts Department of Environmental Protection (MassDEP) 



M13 



encourages the post-closure use oflandfills for renewable energy projects as long as the use will 
not compromise the environmental protection afforded by the landfill cap and closure. MassDEP 
has developed guidance including a fact sheet entitled; "Developing Renewable Energy Facilities 
on Closed Landfills" which is available at http://www.mass.eov/dep/energv/landfill.htm . 

Please let us know by 10 April 2013 if you have any interests or concerns regarding this 
project as related to cultural resources of your Tribe. Your response will aid the 102 nd IW at Otis 
ANG Base in complying with Section 106 of the National Historic Preservation Act of 1966, as 
amended. 

Thank you for your assistance. If you have any questions regarding the proposed project 
or the enclosed materials please contact me at 508-968-4960; email shawmdoyle@ang.af.mil. 



Sincerely, 



SHAWN W. DOYLE, Capt, MA ANG 
Chief, Environmental Management 



Attachment: 

Otis ANGB Solar Array Project Brief 



M13 



Otis ANGB Solar Array Installation Project 

Background and Description 

The 102 nd Intelligence Wing is pursuing a project to install a 4-6 Megawatt solar array on a former 
landfill site. The entire infrastructure of the array will be owned and operated by a third party supplier 
who will sell the energy produced to the 102 ncl IW through a Power Purchase Agreement (PPA). 

The landfill site has been determined to be an excellent location for a solar project by the National 
Renewable Energy Laboratory. Due to its being a capped, managed landfill, the land has little value for 
other purposes. Because maintaining the integrity of the cap is crucial, the solar array will be surface 
mounted with no ground penetrations of any kind. 

The life of the contract will be 20 years, after which the contract and condition of the hardware will be 
re-evaluated to either terminate the agreement or extend It. Upon termination, all solar panels, 
mounting hardware and supporting infrastructure will be removed and the land restored to current 
condition. 

Justification 

A preliminary economic analysis of the PPA shows a potential renewable energy gain of 123 MWh and 
an energy bill savings of up to $6.8 Million over the 20 year life of the project. Even given a worst case 
scenario of no growth in conventional utility prices, a 2% increase in solar power cost per year, and an 
increase in interest rates to 8%, the PPA could still return up to $4.9 Million. 

Timeline 

The Request for Proposal is due to be issued in April 2013, awarded by June. Construction will start in 
September and the system will be online and producing power by January 2014. 



Landfill Area 

Description 

The landfill area is a 66 acre plot of land in a secure part of the Massachusetts Military Reservation that 
was used as a general landfill from the 1940s to the 1970s. Since 1995, it has been capped off and 
managed by the Air Force Civil Engineering Center (AFCEC), which continues to maintain responsibility 
for its management. The capped area is grassland consisting mostly of gentle slopes and large, relatively 
flat areas. 

Solar Array Installation Areas 

The solar array will be built on the grassy areas shown in Figure 2. The forested area is not related to 
the project. For reference purposes, the plot has been divided into areas referred to as Sites 1, 2 and 3. 




Figure 1: Sites of Proposed Solar Array Installation 




DEPARTMENT OF THE AIR FORCE 

102D INTELLIGENCE WING (ACC) 

MASSACHUSETTS AIR NATIONAL GUARD 

OTIS AIR NATIONAL GUARD BASE MASSACHUSETTS 



21 May 2013 

MEMORANDUM FOR RECORD 

SUBJECT: Response to EA by Wampanoag Tribe of Aquinnah 

1 . Several attempts have been made since 13 March, both by letter and by telephone, to notify the 
official office of the Tribe of Wampanoag - Aquinnah of the proposed solar array installation on the 
capped landfill. None of these attempts have been successful. 

2. The Tribe of Wampanoag - Mashpee has responded, stating that, because the site has been so 
heavily disturbed, they have no historical or cultural interest in the site. Because of the prior 
disturbance, it is reasonable to assume the Aquinnah tribe will have a similar response. 

3. The 102 nd CES will continue to attempt to make direct contact with the Tribe of Wampanoag - 
Aquinnah. If these continuing efforts fail, the 30 day public notice period will be taken to be 
sufficient notification. 



y4umc. 



w.<a 



SHAWN W. DOYLE, Capft&in, MA ANG 
Chief, Environmental Management 



M13 




DEPARTMENT OF THE AIR FORCE 

102D INTELLIGENCE WING (ACC) 

MASSACHUSETTS AIR NATIONAL GUARD 

OTIS AIR NATIONAL GUARD BASE MASSACHUSETTS 



17 Apr 2013 
MEMORANDUM FOR RECORD 

FROM Rose Forbes, AFCEC IRP 

322 East Inner Road 
Otis ANG Base MA 02542 

Subject: Discussion with Bourne Conservation Commission on the Landfill Solar Array at 
the Massachusetts Military Reservation (MMR), MA 



1. On 9 Apr 2013, Rose Forbes contacted Brendan Mullaney via email (attached) to discuss the 
proposed solar array project on the MMR base landfill in the Town of Bourne. The purpose of the 
discussion was to inform the Bourne Conservation Commission of the proposed project and 
determine if the Commission had any concerns or required additional information. 

2. Brendan Mullany responded on 9 Apr 2013 stating "The Conservation Commission would only 
have jurisdiction over the project if it was being proposed in the vicinity of any Wetland Resource 
Areas or within a FEMA designated Flood Zone. I am assuming that the proposed project is not in 
one of these two designated areas. Therefore, if the project is not within a FEMA designated Flood 
Zone or within a Wetland Resource Area or the 1 00 foot buffer zone to a Wetland Resource Area, 
than this department has no further concerns with the project." 

3. The proposed solar array on the MMR base landfill is not within a FEMA designated Flood Zone 
or within a Wetland Resource Area or the 100 foot buffer zone to a Wetland Resource Area. 

4. Questions on this Memo for Record should be directed to either Capt Shawn Doyle at 508-968- 
4960 or Rose Forbes at 508-968-4670 x 5613. 

Attachment 

Email to Brendan Mullaney, Bourne Conservation Commission 



FORBES, ROSE H GS-13 USAF HAF AFCEC/CZO 



From: FORBES, ROSE H GS-13 USAF HAF AFCEC/CZO 

Sent: Tuesday, April 09, 201 3 4:08 PM 

To: 'BM ullaney@townofbourne.com' 

Cc: 'Doyle, Shawn W Capt USAF ANG 102 CES/CEO' 

Subject: solar project at MMR 

Attachments: Bourne_12_31272.pdf 

Signed By: rose.forbes@us.af.mil 

Hi Brendan - We are looking to develop a multi-MW solar array project at 
MMR. The project proponent is the 182nd intelligence Wing (102nd IW) at 
Otis ANG Base and the proposed location is the closed base landfill located 
on Connery Avenue in Bourne. The land was used as a landfill starting 
around WWII and was closed and capped in 1995. The 102nd has completed a 
consult with the MA NHESP office (attached) and has agreed on a mitigation 
plan with their office. 

Capt Doyle is the project manager for the solar array development and is 
currently working on an Environmental Assessment (EA). As part of the EA, 
we are conducting consults with the applicable offices. Since the project 
is located in the Bourne area of the base,, we want to check with you to see 
if you have any concerns with a solar development on a landfill cap. If you 
would like to review the project in more detail than this email, we will 
prepare a package for you to review. If you have no concerns , please let us 
know and we will document this email communication it in a Memo for Record. 



Please advise if you would like to receive additional information about this 
project. 

Thank you in advance for your assistance. 

Rose 



Rose Forbes j P.E., GS-13 
322 East Inner Road 
Otis ANG Base MA 02542 
Office: 508-968-4670 x 5613 
Fax: 508-968-4476 
Cell: 210-324-9495 




Commomrealth of Massachusetts 



Divliion off 
Fiiheries & Wildlife 



Mas&WUdWe 



102 nd Intelligence Wing 
Otis Air National Guard Base 
Mass Air National Guard 
158 Reffly Street, Box 22 
Bourne, MA 02352 



Wayne F. MacCallum, Director 
March 1, 2013 



RE: Project Location: Capped landfill on Otis Air National Guard Base 

Project Description: Proposed lease and installation of solar array 
NHESP File No.: 1 2-31272 

Dear Applicant: 

Thank you for submitting the MESA Review Checklist and required materials to the Natural Heritage 
and Endangered Species Program (NHESP) of the MA Division of Fisheries & Wildlife for review 
pursuant to the Massachusetts Endangered Species Act (MESA) (MGL c,131A) and ifs implementing 
regulations (321 CMR 10.00). The proposed project consists of the installation of a 4-6 Megawatt 
photovoltaic solar array on 37 acres of the capped landfill at Otis Air National Guard Base. 

Based on a review of the information that was provided and the information that is currently contained in 
our database, the NHESP has determined that this project occurs within the mapped habitat of the 
Grasshopper Sparrow {Ammodmmus savcmnarum; "Threatened"), Vesper Sparrow {Pooecete$ gramineus 
"Threatened"), and Upland Sandpiper (Bartramia longicauda; "Endangered"). These species are listed 
pursuant to the MESA. 

The NHESP has determined that this project, as currently proposed, will result in a "take" of the 
Grasshop per Sparrow, Vesper Sparrow, and Upland Sandpiper (321 CMR 10.02). The proposed project 
will result in the disruption of feeding, breeding, and migratory behaviors of this species, as well as a loss 
of grassland habitat. A project resulting in a "take" of state-listed species may only be permitted if it meets 
the standards for issuance of a Conservation & Management Permit (CMP){321 CMR 10.23). In order for a 
project to be considered for a CMP, the project proponent must (1) avoid and minimize impacts to state- 
listed species to the greatest extent practical, (2) demonstrate that an insignificant portion of the local 
population will be impacted or that no viable alternative exists, and (3) develop and implement a 
conservation plan that provides a long-term net benefit to the conservation of the local population of the 
impacted species. 

The NHESP anticipates issuing a MESA CMP for this project. This Determination is a final decision of the 
Division of Fisheries and Wildlife pursuant to 321 CMR 10.18. Any person aggrieved by this decision 
shall have the right to an adjudicatory hearing at the Division pursuant to M.G.L. c. 30A, s.ll in 
accordance with the procedures for informal hearings set forth in 801 CMR 1.02 and 1.03. Any notice of 
claim for an adjudicatory hearing shall be made in writing, accompanied by a filing fee in the amount of 
$500.00 and the information specified in 321 CMR1 0.25(3). The notice of claim shall be sent to the 



www.masswildlife.org 



Division of Fisheries and Wildlife 

Field Headquarters, 1 Rabbit Hill Road, Westborough, MA 01581 (508) 389-6300 Fax (508) 389-7891 

An Agency of the Department of Fish and Game 



NHESP File No. 12-31272, Bourne, Otis Solar, Page 2 of 2 

Division's Director, Wayne MacCallum, by certified mail, hand delivered or postmarked within 21 days 
of the date of the Division's Determination. 

No soil or vegetation disturbance, work, clearing, grading or other activities related to the snhjert filing 
shall be conducted anywhere on this project site until the MESA permitting process is completed . If you 
have any questions regarding this review please contact Eve Schluter, Ph.D., Senior Endangered Species 
Review Biologist, at (508) 389-6346 or eve.schhiter@state.ma.us. 

Sincerely, 



/£ fi b ) .. + *» UJ* jPufLcS 



Thomas W, French, Ph.D. 
Assistant Director 

cc: Captain Shawn Doyle, 102 nd Civil Engineering Squadron 




DEPARTMENT OF THE AIR FORCE 

102D INTELLIGENCE WING (ACC) 

MASSACHUSETTS AIR NATIONAL GUARD 

OTIS AIR NATIONAL GUARD BASE MASSACHUSETTS 



17 Apr 2013 

MEMORANDUM FOR RECORD 

FROM Rose Forbes, AFCEC IRP 

322 East Inner Road 
Otis ANG Base MA 02542 

Subject: Discussion with Bourne Historic Commission on the Landfill Solar Array at the 
Massachusetts Military Reservation (MMR), MA 



1. On 9 Apr 2013, Rose Forbes called Mr. Donald Ellis, the Chairmen of the Bourne Historic 
Commission to discuss the proposed solar array project on the MMR base landfill in the Town of 
Bourne. The purpose of the discussion was to inform the Bourne Historic Commission of the 
proposed project and determine if the Commission had any concerns or required additional 
information. 

2. Mr. Ellis stated his opinion is that the landfill cap is the perfect place for a solar array. He did 
not have any concerns with the project as proposed. He stated the nearest historically significant 
area is the Indian Trails, north of the landfill, near the former BOMARC missile site. Mr. Ellis 
requested information on the project so he can brief it to the Bourne Historic Commission members 
at their next meeting. Information will be sent to Mr. Ellis at the Sagamore, MA office. 

3. Questions on this Memo for Record should be directed to either Capt Shawn Doyle at 508-968- 
4960 or Rose Forbes at 508-968-4670 x 5613.